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Capital Gains Real Estate Investments Proposed Regulation

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

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If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

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The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more

McDermott Will & Emery

IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules

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The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that recharacterizes certain net long-term capital gain with...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations and the Impact on Private Equity

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Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more

Troutman Pepper

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper on

Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

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On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more

Sullivan & Worcester

20 Ozone Things to Know for 2020 (Part 1)

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Two months have elapsed since Treasury and IRS issued the Final Regulations on Opportunity Zones. The effective date is March 13, 2020. During these two months, the Sullivan Ozone Practice Group has hosted gatherings for our...more

Jackson Walker

Treasury Releases Final Regulations for Investing in Qualified Opportunity Zones

Jackson Walker on

On December 19, 2019, the Treasury Department released final regulations on the Qualified Opportunity Zone (QOZ) program first enacted in the Tax Cuts and Jobs Act of 2017. Final regulations provide additional safe harbors...more

A&O Shearman

Opportunity Zones: Final Regulations Provide Additional Flexibility

A&O Shearman on

On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to...more

K&L Gates LLP

Opportunity Zone Final Regulations: First Impressions - Final Rules Strive for Balance of Certainty and Flexibility for OZ...

K&L Gates LLP on

Almost exactly two years after enactment in the Tax Cuts and Jobs Act, Treasury has released final regulations on the Opportunity Zone (“OZ”) tax incentive. ...more

Smith Debnam Narron Drake Saintsing & Myers,...

Latest Opportunity Zone Regulations Provide Needed Clarity to Investors, Fund Managers, and Businesses

On April 17, 2019, the United States Department of the Treasury (“Treasury”) issued its second round of proposed regulations related to investments in Qualified Opportunity Zones (“QOZs”) and Qualified Opportunity Funds...more

Obermayer Rebmann Maxwell & Hippel LLP

Part I: Qualified Opportunity Fund Tax Benefits – Not Just For Real Estate Investors

The Treasury Department has issued two sets of proposed regulations concerning the tax benefits available to taxpayers who invest in Qualified Opportunity Funds (QOFs). The first set of proposed regulations (published in...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update New Proposed Treasury Regulations (Part III)

Qualified Opportunity Funds - The Opportunity Zone tax incentive program allows taxpayers that invest in a Qualified Opportunity Fund to (i) defer paying taxes on the capital gain from the sale or exchange of appreciated...more

Ballard Spahr LLP

QOZ Update: IRS Provides Relief for Early Investments of Net Section 1231 Gain

Ballard Spahr LLP on

There are many complex and confusing aspects to the qualified opportunity zone (QOZ) program, and the treatment of Section 1231 gain is no exception.  Internal Revenue Code Section 1231 applies to depreciable property and...more

BakerHostetler

Treasury Provides Further Clarity With Second Set of Proposed Regulations for Investing In Qualified Opportunity Funds

BakerHostetler on

On April 17, the Treasury Department (Treasury) released the second set of proposed regulations concerning investing in qualified opportunity funds (QOFs) and qualified opportunity zones (QOZs) under Section 1400Z-2 of the...more

Arnall Golden Gregory LLP

Qualified Opportunity Zone Frequently Asked Questions

1. Who Can Invest? U.S. or foreign investors and pass-through entities recognizing U.S. capital gains. 2. What Type of Capital Gain Qualifies? Long term and short term capital gains qualify. ...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part II)

Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more

Miles & Stockbridge P.C.

2nd Tranche of OZ Regulations

On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more

McCarter & English, LLP

IRS Issues New Proposed Regulations On Qualified Opportunity Zones

Significant tax incentives for investing in qualified opportunity funds (“QOFs”) that make qualifying investments in low-income census tracts designated as qualified opportunity zones (“QOZs”) were signed into law in December...more

Pillsbury - Gravel2Gavel Construction & Real...

Additional Guidance on Qualified Opportunity Zone Investments Provided by the IRS

On April 17, 2019, the IRS issued its much anticipated second tranche of guidance (the “2019 Proposed Regulations”) on the qualified opportunity zone (QOZ) program established by the 2017 Tax Cuts and Jobs Act. ...more

Tonkon Torp LLP

Opportunity Zones: A Threequel

Tonkon Torp LLP on

Last July, I wrote a blog post on opportunity zones and the importance to investors and professionals of forthcoming guidance from the IRS. The first chapter of that guidance was issued in October 2018, and was the subject of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Second Set of Qualified Opportunity Zone Proposed Regulations Provide Clarity to Potential Investors

As discussed here in November (Why 2019 Will be the Year of Opportunity (Zones)), the Tax Cuts and Jobs Act created a tax-advantaged incentive program for investing in designated “qualified opportunity zones” throughout the...more

K&L Gates LLP

Worth the Wait: Second Round of Opportunity Zone Proposed Regulations Clears the Way for Many OZ Investments

K&L Gates LLP on

After a lengthy drafting and protracted review process, the Department of Treasury (“Treasury”) has released its second set of proposed regulations (the “Second Round Regs”) providing guidance on the implementation of the...more

Partridge Snow & Hahn LLP

IRS Issues Additional Regulations Providing More Clarity To Opportunity Zone Investments

On Wednesday April 17, 2019, the IRS issued the second round of proposed Treasury Regulations for Qualified Opportunity Zones under the Tax Code (the “New Proposed Regulations”). These regulations provide some much-needed...more

McDermott Will & Emery

Treasury Provides Additional Guidance on Opportunity Zone Provisions

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

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